Draft forms for 2016 ACA health coverage reporting are now available

The IRS has published draft versions of the 2016 forms that applicable large employers (ALEs) must use to complete health coverage reporting – Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns. The forms are, so far, merely drafts, and should not be used for filing. The Form 1094-C and Form 1095-C are available at www.irs.gov/pub/irs-dft/f1094c–dft.pdf and www.irs.gov/pub/irs-dft/f1095c–dft.pdf, respectively.

There are some minor changes to the forms for 2016. For example, transition relief indicated on Line 22B of the 2015 Form 1094-C is no longer available, so that information has been removed.

Some of the instructions for Form 1095-C has been simplified and clarified, and more thoroughly explain the employee required contribution at Line 15. Also, two new indicator codes, 1J and 1K, have been added for conditional offers of minimum essential coverage to spouses.

ALEs are required to furnish each full-time employee with Form 1095-C by Jan. 31 of the calendar year following the calendar year to which the information relates. ALEs must also file the information returns Forms 1094-C and 1095-C with the IRS no later than Feb. 28 – or March 31 if filed electronically – of the year immediately following the calendar year to which the return relates.

Also, if an ALE needs to file at least 250 information returns during the calendar year, Form 1095-C and Form 1094-C must be filed electronically. Each full-time employee must be provided with a copy of the Form 1095-C that is filed with the IRS.